Feature Article 
United States International Tax Treaties: A Guide for Early Career Tax Professionals
With increasing international trade and financial activities, United States taxpayers face the risk of double taxation, where two or more countries tax the same income. To mitigate this risk and foster international economic ... Sarah Eddie, EA
Spring 2025,
Feature Article,
international, foreign tax credit, FTC, tax treaty, permanent establishment rules, PE, Langroudi, Mehrdad Hamzeye v. Commissioner, Form 1040NR, US-Belgium Double Tax Treaty, specific anti-avoidance rules, general anti-avoidance rules, LOB, limitation on benefits clauses, GAAR, SAAR, pay-as-you-earn, PAYE
Feature Article
Unmasking the Myths: Who Can Truly Be a Shareholder in an S Corporation?
Revisiting the Basics of the S Corporation: Nonresidents as Shareholders Small business corporations are more popular than ever. You hear about them on social media, and among the tax community. Indeed, sm... Fernando Juarez, EA, and Edgar Gonzalez, EA
Spring 2025,
Feature Article,
TCJA, Tax Cuts and Jobs Act, s corporation, c corporation, GILTI, nonresident alien, ITIN, small business, partnerships, beneficiary, controlled foreign corporation, CFC, SSN, §1362(d)(2), shareholders, double taxation, foreign bank account, green card test, substantial presence test, Treas. Reg. 1.1361-1(g)(1)(i), §7701(b)(1)(B), §7701, Office of the Chief Administrative Hearing Officer, OCAHO, Immigration Reform and Control Act of 1986, Immigration Act of 1990, electing small business trust, ESBT, tax treaty, global intangible low-taxed income, Form 8833, Treas. Reg. §301.7701(b)-7, INTL-121-90, §1361(a)(1), §1361(b)(2)(C), §1362(a), Treas. Reg. §301.7701(b)-7(a)(4), §957, §552